Ameris
Bancorp, a Georgia corporation (the “Company”), hereby transmits for filing the
Company’s responses to comments of the Staff contained in the letter from Mr.
Christian Windsor to the undersigned dated November 13, 2008. For the
Staff’s convenience, the numbered paragraphs below correspond to the paragraph
numbers in the Staff’s November 13, 2008 comment letter.

Form 10-K for the Fiscal
Year Ended December 31, 2007 (the “Annual Report”)

Item 3, Legal Proceedings,
page 21

1.

The
final ruling of the Supreme Court of Alabama in the referenced proceeding
was received on December 12, 2008. In that ruling, the Supreme
Court of Alabama reversed the rulings of the trial court and entered a
judgment in favor of the Company’s former subsidiary, Southland Bank, and
the Southland Bank employee named as a defendant in the
suit. The Company intends to disclose this information in its
future filings.

Signatures, page
51

2.

As
requested by the Staff, the Company’s future filings will identify the
Company’s principal accounting officer. Currently that person
is Dennis J. Zember Jr., the Company’s Executive Vice President and Chief
Financial Officer.

Securities and
Exchange Commisssion

December 24,
2008

Page 2

Form 10-Q for the Period
Ended March 31, 2008 (the “Quarterly Report”)

Note 1, Basis of
Presentation & Accounting Policies, page 6

3.

The
requested reconciliation of Level 3 assets and the disclosure required by
paragraph 32 (c) and (d) of SFAS 157 are provided in Exhibit A to
this letter and will be included in the Company’s future filings, as
requested by the Staff.

The
determination of the fair value of the Company’s derivative instruments is
completed by employing discounted cash flow analysis that includes several
significant other observable inputs. This analysis and these inputs
include the contractual terms of each derivative, including the period to
maturity, interest rate curves and implied volatilities. The fair
values of interest rate swaps are determined using the market standard
methodology of netting the discounted future fixed cash receipts and the
discounted expected variable cash payments. The variable cash
payments are based on an expectation of future interest rates (forward curves)
derived from observable market interest rate curves. In the opinion
of Company management, these significant inputs are Level 2 inputs.

In
addition to these inputs and in compliance with provisions of SFAS 157,
management has considered the impact of credit valuation adjustments to reflect
the risk of nonperformance by the Company’s counterparty. This
consideration of the credit risk of the Company’s counterparty relies primarily
on estimated credit spreads to determine the likelihood of
default. The nature of these inputs leads management to believe that
they are Level 3 inputs.

Management’s
determination has been to place the derivative contracts in the fair value
hierarchy as Level 2. This determination was based on the belief that
credit valuation adjustments are not currently significant to the overall
determination of fair value.

As
stated in the Proxy Statement, the Company has chosen to position cash
compensation of its named executive officers at close to market median
levels, with the allocation of total cash between base salary and annual
bonus based on a variety of factors. Among those factors are
the executive’s performance during the relevant period, the performance of
the Company during the relevant period, the individual business or
corporate function for which the executive is responsible, the nature and
importance of the position and role within the Company, the scope of the
executive’s responsibility and the current compensation package then in
place for that executive. On this basis, the Compensation
Committee of the Company’s Board of Directors determined that increases in
the base salaries of the named executive officers, ranging from $7,290 for
Jon Edwards, the Company’s Executive Vice President and Director of Credit
Administration, to $50,000 for Edwin W. Hortman Jr., the Company’s
President and Chief Executive Officer, were warranted in
2007. Additional information regarding the base salary
adjustments is set forth under the caption “2007 Evaluation of CEO
Compensation and Executive Performance” in the Proxy
Statement.

With
respect to annual bonuses, the Committee determined a minimum level of Company
earnings to be applicable during fiscal year 2007 for determining whether the
named executive officers would receive incentive compensation. This
minimum level of earnings for fiscal year 2007 was not reached and,
consequently, no incentive compensation was payable to the named executive
officers for that period.

As
requested by the Staff, the Company will disclose in its future filings the
methodology used by the Committee to determine the level of each compensation
element and how that methodology resulted in the compensation paid to executives
in the relevant period.

Securities and
Exchange Commisssion

December 24,
2008

Page 3

5.

As
requested by the Staff, the Company will identify in its future filings
any consulting firms retained by the Company in determining or
recommending the amount or form of executive and director
compensation.

6.

As
requested by the Staff, the Company will disclose in its future filings
the manner in which any peer group data, and the members of any such peer
group, is used by the Compensation Committee of the Company’s Board of
Directors for benchmarking total compensation or any material element of
compensation of the Company’s named executive
officers.

7.

As
requested by the Staff, the Company will disclose in its future filings
the Company’s use of targets to award different types of compensation to
the Company’s named executive officers. Such information will
be included even where no compensation was awarded in connection with the
Company’s use of such targets.

Stock Ownership Guidelines,
page 10

8.

As
requested by the Staff, the Company will quantify in its future filings
the number or amount of shares of Company stock required to be owned by
the Company’s executive officers and directors, if
any.

Certain Relationships. . .,
page 27

9.

As
requested by the Staff, the Company will include in its future filings the
complete representation regarding loans to insiders required by the
instructions to Item 404(a) of Regulation S-K, including clarification
that the loans were made on the same terms, including interest rates, as
were available to other persons not related to the Company or its banking
subsidiary.

Securities and
Exchange Commisssion

December 24,
2008

Page 4

* * *

The
Company hereby acknowledges that: (i) the Company is responsible for the
adequacy and accuracy of the disclosure in the Annual Report, the Quarterly
Report and the Proxy Statement; (ii) Staff comments or changes to the disclosure
in response to Staff comments do not foreclose the Commission from taking any
action with respect to the Annual Report, the Quarterly Report or the Proxy
Statement; and (iii) the Company may not assert Staff comments as a defense in
any proceeding initiated by the Commission or any person under the Federal
securities laws of the United States.

Any
comments or questions regarding the Annual Report, the Quarterly Report, the
Proxy Statement or this letter should be directed to the undersigned at
telephone (229) 890-1111 or facsimile (229) 890-2235.